Pye v. Nu Aire, Inc., et al., No. 10-2243 (8th Cir. 2011)
Annotate this CaseAppellant appealed from the district court's grant of summary judgment in favor of his former employer on his claims of race discrimination, hostile work environment, and termination as a result of retaliation in violation of Title VII of the Civil Rights Act of 1964, 41 U.S.C. 2000e-2000e-17, and the Minnesota Human Rights Act, Minn. Stat. 363A.15 ("MHRA"). The court held that the district court correctly determined that the former employer was entitled to summary judgment on the harassment/hostile work environment claim where appellant failed to establish the threshold of actionable harm necessary to constitute a hostile work environment. The court also held that the district court correctly granted summary judgment on appellant's claims that he was fired on the basis of his race, and treated less favorably than similarly-situated white employees on the job where appellant presented no direct evidence that his termination or alleged lack of training or job change opportunities were racially motivated. The court held, however, that the district court erred in granting summary judgment on appellant's retaliation claims where he had produced sufficient evidence of retaliation.
Court Description: Civil case - employment discrimination. District court did not err in finding defendant was entitled to summary judgment on plaintiff's harassment/hostile work environment claim as plaintiff failed to establish the actionable harm necessary to constitute a hostile work environment; with respect to plaintiff's claim that he was fired on the basis of his race, he failed to show that he was treated differently than similarly-situated white employees; the district court erred in granting defendant summary judgment on plaintiff's claim that he was retaliated against after he filed a discrimination complaint as there was sufficient evidence of a causal link between the complaint and the termination to preclude summary judgment.
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